Rodney W. Taras and Linda K. Taras - Page 15

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          expenses in all years.  Even assuming that petitioners were able            
          to reduce their board and veterinary expenses to zero for all               
          years, total losses would have only been reduced by approximately           
          40 percent.  In the face of successive or increasing losses,                
          petitioners have failed to materially alter their operations or             
          their prospects of generating profits.  Golanty v. Commissioner,            
          supra at 428.                                                               

          Expertise                                                                   

               Preparation for an activity by extensive study of its                  
          accepted business, economic, and scientific practices, or                   
          consultation with those who possess expertise in the activity,              
          may indicate that the taxpayer has a profit objective.  Sec.                
          1.183-2(b)(2), Income Tax Regs.                                             
               Mr. Taras grew up on a farm and worked with horses during              
          those years.  Mr. Taras also became a member of the Pennsylvania            
          Breeders Association and educated himself through industry                  
          publications.  Petitioners sought out, consulted with, and hired            
          professional racehorse trainers and breeders throughout the years           
          of operation of their activity.  Petitioners followed the advice            
          of Ms. Audrey Kraynik, who represented that she was a licensed              
          trainer experienced in training racehorses.  With respect to the            
          breeding of their horses, petitioners consulted with two horse              







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